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United States v. Manzella,
No. 06-3434 (3rd Cir., February 2, 2007): Federal Sentencing Guidelines: A district court cannot justify a longer sentence for a defendant based on its reasoning that the longer sentence is necessary for rehabilitative purposes. In this case, the defendant's sentence under the Guidelines was one month, but the defendant needed a 30-month sentence to be eligible for the 500-hour BOP drug treatment program, which the district court thought necessary and accordingly it imposed a 30-month sentence. The Circuit relied on a more specific statute, 18 U.S.C. sec. 3582(a), to conclude that imprisonment is not an appropriate means of promoting correction and rehabilitation. Accordingly, rehabilitation is a factor to be considered when imposing a non-imprisonment alternative sentence.
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